The problem with that theory is that there is no court order sealing Obama’s records. The records of his that are confidential are the same as for any other person.
And in 21st century “Wiki leaks-Edward Snowden America,” there is no such thing as a “sealed record.” Any record can be hacked and released, even our most top secret national security files. And any record that was sealed by a court can be unsealed by a different court if there is probable cause.